Court : Income Tax Appellate Tribunal ITAT Ahmedabad
Decided on : Dec-30-1993
Reported in : (1994)50ITD66(Ahd.)
..... the case of cit v. smt. kamalini khataul 1978] 112 itr 652. at pages 661-662, the court has compared the words used in the first proviso to section 41(1) of it act, 1922 and the corresponding provisions of section 164 of it act, 1961. the words used in the old proviso to section 41(1) were "the tax shall be levied upon and recoverable" while under the ..... act of 1961 the words used are "tax shall be charged". after comparing the effect of the different expressions "charged" and "levied ..... these trusts in which copies of the respective trust deeds, copies of statement showing valuation of life interest, remaindermen's interest for the various years under consideration were submitted. these charts showing valuation of life interest and remaindermen's interest and balance surplus value were submitted with a view to provide the basic information to the assessing officer as regards value ..... and came to the conclusion that the ratio of madras high court decision is not correct. he followed the decision of calcutta high court in surendranath gangopadhyaya trust v. cit  142 itr 149 and the m.p. high court in piarelal sakseria family trust v. cioot  136 itr 583 and came to the conclusion that provisions of .....Tag this Judgment!